Personal Data Protection and Cookie Policy

Whereas Georgia has introduced legislation on Personal Data Protection (Law on “Personal Data Protection”, dated July 3, 2023) to ensure the protection of human rights and freedoms, including privacy, when processing personal data. “Nutrimax” LLC (identification number: 206330709, hereinafter the “Company”) has implemented a data privacy policy, in order to ensure the rights of the consumers (hereinafter the “Data Subject”) of, a website, created to advertise and sell the company’s products.

The data subject is obliged to familiarize him/herself to the present policy and in case of his/her own will, confirm it, accordingly, provide the consent on processing his/her personal data, by marking the consent sign below.

In accordance with the legislation of Georgia, this policy defines the processing and storage of personal data of data subjects.

The latter includes information that the Company receives during the provision of services to Data Subject, which, in accordance with the legislation of Georgia, may subsequently also be used for direct marketing purposes. The purpose of the notice is to provide the Data Subject with information about the principles of our work in the processing of personal data and the mechanisms for their use.

The Company warrants that:

  • Ensures the confidentiality of the personal data of the Data Subject;
  • Ensures the security and protection of personal data of the Data Subject;
  • Will not use the personal data of the Data Subject improperly;
  • At any time, the Company will provide the Data Subject full and comprehensive information regarding processing his/her personal data.

1. Definitions

1.1. Personal data – any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, including by his/her name, surname, identification number, location data and electronic communication identifiers, or by physical, physiological, mental, psychological, genetic, economic, cultural or social characteristics;
1.2. Data Subject – any natural person whose data are being processed;
1.3. Processing of Personal Data – any operation performed on personal data, including collecting, obtaining, accessing, organizing, grouping, interconnecting, storing, altering, retrieving, requesting for access, using, blocking, erasing or destroying, and disclosing by transmission, publication, dissemination or otherwise making available;
1.4. Direct Marketing – the direct and immediate delivery of information to a data subject by telephone, mail, email or other electronic means to generate and maintain interest in, sell and/or support a natural and/or legal person, product, idea, service, work and/or initiative, as well as image and social issues. The provision of information by a public institution to a natural person shall not be considered direct marketing if the provision of such information is compatible with any of the grounds for data processing as provided for by Articles 5 and 6 of the Personal Data Protection law.
1.5. Written Consent of Data Subject – after receiving the relevant information by the Data Subject, the voluntary consent expressed by the Data Subject to the processing of his/her data, for the specified purpose, which the Data Subject has signed or otherwise noted in writing or in an equivalent form (in case of this policy, by marking the consent sign indicated below);
1.6. Person Responsible for Data Processing – a natural person, a legal person, or a public institution, who individually or in collaboration with others determines the purposes and means of the processing of data, and who directly or through a processor processes data (for the purpose of the present policy Marketing Department of the Company.

2. Personal data which can be processed by the Company, using website

Within the scope of the activities of website and this policy, the Company will process the following data of the Data Subject:

  • Name and surname of the Data Subject;
  • E-mail address of the Data Subject.

The Company can receive the personal data, personally, from the Data Subject.

3. Purpose and basis of processing of the personal data

The processing of personal data of the Data Subjects, can be conducted for the purpose of carrying out the Company’s marketing activities and ensuring the standard functioning of the website.

The base of processing the personal data is the consent of the Data Subject.

4. The rights of Data Subject

In accordance to the law of Georgia on Personal Data Protection, the Data Subject is entitled to request the Company information regarding processing of his/her personal data. The Data Subject is entitled to receive the following information:

  • Which data concerning him/her are being processed, as well as the grounds for and the purpose of the processing;
  • The source from which the data were collected/obtained;
  • The period for which the data will be stored and, if no specific period can be determined, the criteria used to determine that period;
  • The right of the data subject as provided for by the law of Georgia on Personal Data Protection;
  • The legal basis and purposes of the data transfer, as well as the appropriate data protection safeguards if the data are transferred to another state or an international organization;
  • The identity of the recipients or the categories of recipients, including information on the ground for and purpose of the transfer, if the data are transferred to a third party;
  • The decision made as a result of automated processing, including profiling, and the logic involved in making such a decision, as well as its impact on the processing and the expected results of the processing.

In addition to the aforementioned, the Data Subject is also entitled to:

  • Become familiar with the personal data, about him/her, with a person responsible for processing the data, request their copies, as well as, to correct, update and/or fill in false, inaccurate and/or incomplete data about him/her, to stop data processing, to delete, destroy and/or block data (temporary suspension of processing);

Person, responsible for processing the data may continue processing the data, or may not delete/destroy the data of Data Subject, despite of his/her request, in case, other legal base for the processing of data exists.

  • At any time, by written notice to the Company, without any explanation, withdraw his/her consent to the processing/collection/transfer of his/her personal data. In this case, data processing will be stopped and/or processed data will be deleted/destroyed, in accordance to the request of the Data Subject, no later than 10 working days after the Data Subject’s request (in case the data is processed for direct marketing purposes, within 7 calendar days from the Data Subject’s request), if there are no other grounds provided by the Law of Georgia on Personal Data Protection.
  • Other rights, established by the law of Georgia on Personal Data Protection.

5. Method of processing the personal data

The specific user will be identified using the Data Subject’s personal information, as well as the information regarding activities carried out by the Data Subject in the website. When a Data Subject participates in activities through the Company’s website, in case of Data Subject’s will, he/she indicates the following information:

  • Name;
  • Surname;
  • E-mail address

It is not obligatory to conduct the identification activities.

The data will be processed by the Company, in accordance with the Georgian legislation.

The person responsible for data processing shall be the Marketing Department of the Company (Phone number: +995 32 2305335; E-mail address: [email protected]). The contact with the person responsible for data processing may be conducted with the “contact” field on the website, from which the Data Subject sends the notice.

Company has the right to perform any actions in relation to processing the personal data for the above purposes, including: collection, systematization, storage, correction (updating, modification), use, depersonalization, blocking, deletion/destruction, as well as the implementation of any other actions with personal data, taking into account the requirements of the applicable legislation of Georgia.

The Company does not transfer the personal data to the third party (including transborder transfer). Accordingly, only the Company receives the data of the Data Subject.

In addition, the Company’s website collects information about cookies, navigation, and user behavior on the website, namely:

  • IP address, device type, operating system, and browser from which the website is accessed;
  • About the pages opened on the website, session duration, and various session settings.
  • Information about activities that have taken place on the Company’s website: using interactive elements of the website, etc.;
  • The process, time and form of filling in the fields on the site.

The types of Cookie files are:

  • Necessary cookie files are required for the operation of the basic functions of the website, navigation on the page and safe use;
  • The main purpose of functional cookie files is to remember certain choices made by the Data Subject on the website, so that he/she does not have to make this choice again every time he/she visits, for example, consent to the website usage rules and cookie policy;
  • Analytical cookie files collect information about the behavior of the website and its users, data subjects. depending on which part and segment of the website the data subject interacts with.

Cookie files can be deleted from the web browser settings on the data subject’s device. After deleting the cookies, the website will again ask for consent to the Cookie Policy and Terms of Use.

Company shall receive the personal data, from the Data Subject, in a following cases: 

  • When Data Subject uses the website;
  • When the Data Subject indicates his/her name and surname in the “Subscription” field, and/or indicates his/her e-mail address in the “Contact” field;
  • When Data Subject sends the notifications, in both material and electronic form.

6. The period of storage of the personal data of the subject

The Company stores the personal data of the Data Subject within the period of existence of the website. Therefore, the processing of data will stop and data will be destroyed/deleted when the website is cancelled, except the cases, when the Data Subject refers to the Company, regarding the destruction/deletion of his/her data or any other modification, withdraws his/her consent to the processing of personal data and/or there are other cases provided for by the legislation of Georgia.

7. Amendments in the present policy

Company reserves the right to modify this Personal Data Protection and Cookie Policy, at any time. Any modifications made to the present policy will immediately be posted on the Company’s website and elsewhere, which ensures that the Data Subject, regarding the modifications. In addition, the data subject will be notified of any material changes to this policy by posting an appropriate notice on the home page of the website. After the familiarization of the modifications, in case of such need, the Data Subject provides with the consent for processing his/her personal data, again.

It is obligation of the Data Subject to periodically check the Personal Data Protection and Cookie Policy.

8. Marketing

Company may use the Data Subject’s personal data to promote specific products and offers.

Company has access to the subject’s personal data to the extent that he/she him/herself shares.

Company will study the subject’s personal data in order for the company to understand what the data subject needs, what the Data Subject is interested in and what services or offers may be suitable for him/her.

In case of processing the data for the purpose of direct marketing, the Company will process the data, in accordance to the article 12 of the law of Georgia on Personal Data Protection.

In case the Data Subject provides the consent, as a result of familiarization of this policy, he/she also declares that he/she agrees on the terms and conditions of this policy and grants the Company right to process his/her personal data, in accordance to the Georgian legislation and in the scope of the purposes, indicated in this policy. Data Subject also expresses the consent on processing the personal data, indicated in this policy, for the purposes of direct marketing. The Data Subject can at any time withdraw the mentioned consent.